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Archived Transcript for 15 January 2002: Pages
1 to 50
1
1 Tuesday, 15th January 2002
2 (10.00 am)
3 THE CHAIRMAN: Morning ladies and gentlemen, Mr Garnham.
4 MR GARNHAM: Good morning sir. As you know, our first
5 witness this morning is Ms Carole Baptiste. She is
6 represented today by Mr Peter Herbert who sits in the
7 third row of counsel's seats. I have been asked to ask
8 you for a five minute adjournment. Mr Herbert has
9 a matter that he says is of some importance that he
10 wants to raise with me. I have to say it seems to me
11 there would be some profit in doing that. I would
12 prefer to know what it is that is being raised before
13 I call Ms Baptiste rather than having to deal with it as
14 we go, so could I ask you to rise for five minutes?
15 THE CHAIRMAN: Mr Garnham, I am perfectly willing for that
16 to happen. As I think you know, I wanted to say
17 something about Phase II. Would it be convenient, do
18 you think, if I were to say that and then rise?
19 MR GARNHAM: Perfectly convenient sir, thank you.
20 THE CHAIRMAN: Ladies and gentlemen, I thought that it might
21 be helpful if I said something about Phase II in order
22 to give you as early notice as possible about the
23 arrangements that are being made.
24 You will recall that our terms of reference require
25 the Inquiry, and here I quote, "to reach conclusion as

2
1 to the circumstances leading to Victoria Climbie's death
2 and to make recommendations to the Secretary of State
3 for Health and to the Secretary of State for the Home
4 Department as to how such an event may as far as
5 possible be avoided in the future."
6 In large part the evidence upon which I base my
7 recommendations is the evidence heard in Phase I of the
8 Inquiry, but I have always recognised that there will be
9 some matters of more general relevance that relate to
10 that part of our terms of reference and that I would be
11 assisted in having the views of a wider constituency
12 than we have had during Phase I. So the purpose of
13 Phase II of the Inquiry is to seek those wider views.
14 In September 2001 we circulated a draft framework
15 document for Phase II and invited representations on it.
16 I am very grateful indeed to all those who have so
17 helpfully responded. In the light of that material we
18 have identified a series of issues and questions that it
19 seems to me would benefit from further consideration.
20 We will shortly be circulating a paper that sets out
21 these issues and questions. That paper will form the
22 basis of two pieces of work for Phase II. First, I will
23 invite any person or organisation who has views on the
24 subjects raised to write to me setting out their
25 response to those matters. Careful consideration will

3
1 be given to all the responses received. I will then
2 identify all of the responses which seem to me to be
3 both relevant and of value to the Inquiry. These
4 responses will be treated as evidence to the Inquiry.
5 They will be collected together and copies will be made
6 available to anyone wishing to see them. I also hope to
7 be able to publish that evidence on the Inquiry's
8 website.
9 Second, we will be conducting a series of seminars
10 at which the topics identified in the paper will be
11 discussed. I have invited Neil Garnham QC to chair
12 these seminars and he has kindly agreed to do so. I am
13 most grateful to him for that. Each seminar will be
14 held in this room in public and the written media will
15 be free to attend if they wish. Between 12 and 20
16 people will be invited to participate in each seminar.
17 We will clearly endeavour to ensure that there is an
18 appropriate spread of interest and expertise in each
19 seminar. However, people will be invited to participate
20 on an individual basis and not as representatives of any
21 organisation.
22 The seminars will be observed by the assessors
23 sitting with me and me, and we may take the opportunity
24 at the end of each seminar to ask the contributors
25 further questions in order to clarify our understanding

4
1 of the points that they have made. The content of each
2 seminar will be recorded on LiveNote in the usual way
3 and treated as evidence to the Inquiry. As has been the
4 practice in Phase I, a daily transcript of that evidence
5 will be published on the Inquiry website.
6 Arrangements will be made for members of the public
7 to suggest questions during the course of the seminar,
8 but it will be entirely at the discretion of Mr Garnham
9 which additional questions should be considered.
10 Provisionally I can say that the seminars will be
11 programmed to run from mid-March until the end of April.
12 The final arrangements will be publicised as quickly as
13 possible. Each seminar will be scheduled to last from
14 10 am until 4 pm with a suitable break for lunch. The
15 title for each seminar and the issues to be discussed
16 will be set out in a paper to which I have referred.
17 There will be no preliminary meeting for Phase II.
18 The arrangements I have indicated this morning will
19 be published on the Inquiry's website. I have decided
20 that there will be no interested parties for Phase II.
21 I expect personal invitations to those who are to be
22 asked to contribute to each of the seminars to be sent
23 out in the course of the next week or so. I hope that
24 having that information will be helpful but I assure you
25 that we will get the final arrangements publicised just

5
1 as quickly as possible.
2 Thank you very much. Now, in the light of
3 Mr Garnham's suggestion we will adjourn for five
4 minutes. Ladies and gentlemen, thank you.
5 (A short break)
6 THE CHAIRMAN: Ladies and gentlemen, Mr Garnham, I should
7 have said earlier on, you will have observed and I am
8 delighted that Dr Adjaye is back with us now, but sadly
9 Detective Superintendent Fox has got to leave later this
10 morning but he will of course have access to the
11 transcript of the evidence.
12 MR GARNHAM: Thank you sir. Sir, more in hope than
13 expectation I call Carole Baptiste. It was indicated to
14 me at the end of the conversation I had with Mr Herbert
15 that she was at that time in the shopping centre
16 downstairs. I had hoped she might have made it
17 upstairs. It appears she is not here yet. I suggest we
18 simply wait.
19 THE CHAIRMAN: Yes, not indefinitely we will wait. (Pause).
20 MS CAROLE BAPTISTE (sworn)
21 MR GARNHAM: Ms Baptiste, please have a seat. It gets quite
22 warm, you may be more comfortable without hat and scarf
23 and gloves and coat. Would you be more comfortable
24 without your hat and scarf and gloves and coat?
25 MS BAPTISTE: I am fine at the moment thank you.

6
1 MR GARNHAM: Although we have a microphone system in this
2 room you may have to keep your voice up a little, I am
3 afraid.
4 Would you begin by giving the Inquiry your full
5 name.
6 MS BAPTISTE: My full name is Carole Baptiste.
7 MR GARNHAM: And your current professional address if you
8 have one.
9 MS BAPTISTE: I do not have one.
10 MR GARNHAM: We need an address to which we can direct
11 correspondence if we need to. Can you give us an
12 address that we can use, please.
13 MS BAPTISTE: My solicitors.
14 MR GARNHAM: What is that address please?
15 MS BAPTISTE: Fisher Meredith.
16 MR GARNHAM: Do you know their address?
17 MS BAPTISTE: Stockwell, SW4.
18 MR GARNHAM: Thank you very much. During the course of the
19 break that we will probably have mid-morning could you
20 speak to your counsel please for this purpose and this
21 purpose only, to get us the full address of your
22 solicitors so that we can have that on the record,
23 please. Will you do that?
24 MS BAPTISTE: It is Clapham Road, Stockwell, SW4.
25 MR GARNHAM: Thank you. Ms Baptiste I am not going to ask

7
1 you any questions that might be thought to prejudice the
2 criminal proceedings that are afoot in Camberwell
3 Magistrates Court. If there are questions which your
4 counsel believes would cause that type of prejudice then
5 doubtless he will raise the matter. I think it is right
6 Ms Baptiste that you hold a social science degree. Is
7 that right?
8 MS BAPTISTE: Yes.
9 MR GARNHAM: When did you obtain that? When did you get
10 your degree Ms Baptiste?
11 MS BAPTISTE: I think around the 1980s, but I cannot be
12 certain.
13 MR GARNHAM: And you also obtained a diploma in social work,
14 yes?
15 MS BAPTISTE: That is in my statement.
16 MR GARNHAM: Yes, there are going to be a number of
17 questions that may be in your statement but I need your
18 answer to them please. Did you obtain a diploma in
19 social work?
20 MS BAPTISTE: That is correct.
21 MR GARNHAM: Do you remember when that was?
22 MS BAPTISTE: Not offhand.
23 MR GARNHAM: Which decade? Which decade please?
24 MS BAPTISTE: 1980, I think, I believe it was around the
25 late 1980s.

8
1 MR GARNHAM: Thank you. Was Haringey your first employer
2 after you qualified as a social worker?
3 MS BAPTISTE: I believe so.
4 MR GARNHAM: You worked I think as an HIV and Aids social
5 worker from December 1990 until 1993?
6 MS BAPTISTE: I definitely did.
7 MR GARNHAM: Then you moved into the Advice and Assessment
8 Team at Haringey doing generic social work?
9 MS BAPTISTE: Yes.
10 MR GARNHAM: You say, paragraph 4 of your statement if you
11 want to look at it, that you started work as an Acting
12 Manager in the Advice and Assessment Team later on that
13 year.
14 MS BAPTISTE: Sorry, could you repeat the question again?
15 MR GARNHAM: Look at paragraph 4 of your statement please.
16 You told us that in 1993 you began work in the Advice
17 and Assessment Team. Were you made Acting Manager at
18 some stage in that team?
19 MS BAPTISTE: Not in the same team, no.
20 MR GARNHAM: I see. What team was it?
21 MS BAPTISTE: It was the Advice and Assessment Team for
22 a different area office.
23 MR GARNHAM: Do you recall when it was you started in that
24 acting up capacity?
25 MS BAPTISTE: It was approximately 1995.

9
1 MR GARNHAM: Thank you. I wonder if you can be given
2 volume 29A, please, page 000.580. This is an extract
3 from your personnel file prepared I think by Haringey
4 Social Services and at the foot of that page there is
5 a summary of your career with Haringey. According to
6 that you were a Team Manager between 11th July 1994 and
7 24th November 1997 initially. Do you recall that? Is
8 that right? Is that about right? If you cannot
9 remember the details ...
10 MS BAPTISTE: Yes, I guess it must be. I have not had an
11 opportunity to look at all the documentation so I have
12 to accept the information that you have presented before
13 me.
14 MR GARNHAM: You then went on maternity leave I think.
15 MS BAPTISTE: Yes, I did.
16 MR GARNHAM: And you were on maternity leave from
17 November 1997 until the 15th June 1998, is that right?
18 MS BAPTISTE: I believe, yes, I believe it was around that
19 time.
20 MR GARNHAM: What work did you do on your return from
21 maternity leave?
22 MS BAPTISTE: On returning from maternity leave I was then
23 placed in the Advice and Assessment Team.
24 MR GARNHAM: Really? Not the Investigation and Assessment
25 Team?

10
1 MS BAPTISTE: I suppose it is semantics, but yes,
2 Investigation and Assessment Team.
3 MR GARNHAM: I hope it is not semantics. I think they are
4 two different teams, are they not, the Advice and
5 Assessment Team and the Investigation --
6 MS BAPTISTE: Sorry, you are absolutely right. Sorry, it
7 has just been a very long time since I have been in the
8 field so I am having to think how things were.
9 I returned to the Investigation and Assessment Team
10 which had a different remit to the Advice and Assessment
11 Team.
12 MR GARNHAM: You worked full-time for that team until the
13 beginning of October 1998. Is that right? Is it right?
14 MS BAPTISTE: I cannot say. I do not remember.
15 MR GARNHAM: Is it right that you eventually went part-time,
16 working half a day a week [sic]?
17 MS BAPTISTE: My recollection is that I returned to work
18 part-time and then subsequently started working
19 full-time.
20 MR GARNHAM: I see. And you worked two and a half days
21 a week during that period of part-time work. Is that
22 right? I think you worked Monday, Tuesday and the first
23 part of Wednesday.
24 MS BAPTISTE: That is correct. That is correct.
25 MR GARNHAM: In that same volume please, I wonder if you

11
1 could be helped, could you turn to page 536. 000.536 in
2 that volume is a memo written by you to Tina in the
3 Personnel section. Do you see that?
4 MS BAPTISTE: Yes, I do.
5 MR GARNHAM: That indicates that you had negotiated with
6 your manager Dave Duncan to go part-time with effect
7 from 30th September 1998 for a period of six months. Is
8 that what you recall? Is that right?
9 MS BAPTISTE: Yes, I did write this memo, yes.
10 MR GARNHAM: If you turn to page 537, the next page, again
11 can you be helped please, that is a memo copied to you
12 but sent to Personnel from Mr Duncan indicating that you
13 are to go part-time from 28th September for up to six
14 months working 17 and a half hours a week.
15 MS BAPTISTE: Yes.
16 MR GARNHAM: During the period when you worked part-time,
17 end of 1998, beginning of 1999, what happened to your
18 responsibilities for the half week you were not there?
19 Do you know?
20 MS BAPTISTE: I am not absolutely clear.
21 MR GARNHAM: You do not know who was looking after your
22 team, because you were an Acting Team Manager at the
23 time, for the second half of the week?
24 MS BAPTISTE: There was not anybody officially appointed.
25 MR GARNHAM: Yes, you say in paragraph 21 of your statement

12
1 that the Council, Haringey, were unwilling to appoint
2 a part-time manager in your absence.
3 MS BAPTISTE: That was my recollection.
4 MR GARNHAM: That is not quite right, is it? The reality is
5 they tried but were unable to find part-time cover for
6 you. You may not know, in which case tell us.
7 MS BAPTISTE: I am not sure how to respond to that.
8 MR GARNHAM: Either you know or you do not know.
9 MS BAPTISTE: That is what I am saying, I do not know how to
10 respond to that. My recollection was there was the
11 issue about funding, there was a lot of emphasis about
12 the workload and the need for that post to be filled,
13 and I believe my understanding at that time was that it
14 would not be filled because of the possible prospect of
15 restructuring, but memory, my memory is not that
16 reliable of that time.
17 MR GARNHAM: I see. Thank you for that. Your part-time
18 work was extended I think in March 1999, is that right?
19 You decided to carry on being part-time for a bit
20 longer?
21 MS BAPTISTE: I do not remember.
22 MR GARNHAM: Let me see if I can help you. Go on to
23 page 541 in that bundle. Memorandum of 18th March from
24 somebody in Personnel to Mr Duncan:
25 "With regard to Carole's temporary appointment, she

13
1 is currently working on a job share basis. This
2 arrangement was for a period of six months to
3 31st March. Can you please confirm whether this is to
4 continue after this period and if so for how long."
5 Mr Duncan has endorsed that memo:
6 "Please continue for another six months. Situation
7 is unclear. Long-term given the reorganisation."
8 Does that fit with your recollection?
9 MS BAPTISTE: Yes, it does.
10 MR GARNHAM: In fact you did not need the whole of that
11 additional six months because I think it is right you
12 returned to work full-time on 1st June 1999. Is that
13 right? You are nodding.
14 MS BAPTISTE: I am not absolutely sure. I do not recollect
15 the dates but I am sure that is probably correct.
16 MR GARNHAM: Turn over to page 556 in that bundle please.
17 Memo from you to Personnel:
18 "This is to inform you that I will be returning to
19 work full-time from 1st June 1999."
20 Yes?
21 MS BAPTISTE: Yes.
22 MR GARNHAM: Jumping ahead a little, your employment with
23 Haringey was finally terminated, was it not, on
24 28th February of the year 2000?
25 MS BAPTISTE: That is correct.

14
1 MR GARNHAM: So altogether you were a Team Manager in one
2 capacity or another for five and a half years?
3 MS BAPTISTE: Yes.
4 MR GARNHAM: During how much of that time were you an acting
5 up manager and what proportion were you an established
6 manager? Were you acting up throughout?
7 MS BAPTISTE: Yes, I was.
8 MR GARNHAM: If we go to page 560 in that same volume, we
9 have there a copy of the contract between you and
10 Haringey which indicates that you are employed as
11 a temporary Team Manager, I think that means you are
12 acting up, in accordance with a letter of 22nd December
13 1998. Is that right?
14 If we go back to page 540, we have that letter and
15 we can see that that is a letter from the Director of
16 Housing and Social Services offering you an appointment
17 as a temporary Team Manager in December 1998, explaining
18 that the reason for the temporary nature of the
19 secondment is the absence on secondment of the permanent
20 post holder. Is that right? You are nodding.
21 MS BAPTISTE: Yes.
22 MR GARNHAM: Thank you. Were you able Ms Baptiste to apply
23 for a post as a Team Manager following restructuring
24 when at the time you were acting up rather than in
25 a substantive role? Was that permissible?

15
1 MS BAPTISTE: My understanding at the time was I was told
2 that they were not quite sure because of my status
3 whether I would go forward to the interviews.
4 MR GARNHAM: We know that in fact you did.
5 MS BAPTISTE: Yes, I think subsequently a decision was made
6 that I would be --
7 MR GARNHAM: Eligible?
8 MS BAPTISTE: Considered, or eligible, whatever term you
9 want to use, but I know there was some discrepancy about
10 that.
11 MR GARNHAM: Thank you. May I ask you a little about your
12 duties as an acting up Team Manager. You describe those
13 duties in paragraphs 9 to 19 of your statement and I am
14 not going to take you through each of those paragraphs
15 but you see them in your statement, do you? Yes?
16 MS BAPTISTE: Did you say paragraph 19?
17 MR GARNHAM: 9 through to 19.
18 MS BAPTISTE: Okay. Yes.
19 MR GARNHAM: You tell us during the course of those
20 paragraphs that staff at the North Tottenham District
21 Office where you were working were overloaded with work.
22 MS BAPTISTE: That is right.
23 MR GARNHAM: Each social worker you tell us had between 12
24 and 18 cases.
25 MS BAPTISTE: That is correct.

16
1 MR GARNHAM: And six of them had to be child protection
2 cases, such were the rules that were being operated?
3 MS BAPTISTE: That is my recollection, yes.
4 MR GARNHAM: Our papers include a copy of a set of
5 procedures devised by your colleague Angella Mairs.
6 I wonder if you can be shown that. It is volume 26A
7 page 10. Do you have 26A page 10?
8 MS BAPTISTE: Yes, I do.
9 MR GARNHAM: That is a document entitled "Duty Investigation
10 and Assessment Team" and that is a set of procedures
11 which we see from the last page was devised by
12 Angella Mairs.
13 MS BAPTISTE: Yes.
14 MR GARNHAM: You are familiar with that I imagine?
15 MS BAPTISTE: Not now but I was then.
16 MR GARNHAM: You were?
17 MS BAPTISTE: Yes.
18 MR GARNHAM: Would you go to page 19. We see there
19 a section headed "Case Load for Individual Workers":
20 "When DIA Social Worker is not on duty, he/she will
21 carry a maximum of nine child protection cases,
22 a maximum of three family support cases, between 10 to
23 12 at any one time."
24 Now, on the face of it that is different from what
25 you have told us was the reality. That is an accurate

17
1 picture of the position, is it, that the Angella Mairs
2 document would appear to proscribe a limit of 12 cases
3 but in reality social workers carried up to 18 cases?
4 MS BAPTISTE: That is correct.
5 MR GARNHAM: Given your experience as a social worker
6 Ms Baptiste, did you regard that sort of workload,
7 18 cases, as a reasonable one for a social worker?
8 MS BAPTISTE: That is a difficult question to answer because
9 there are a lot of variables.
10 MR GARNHAM: I imagine it depends on the nature of the cases
11 that the social worker has got on.
12 MS BAPTISTE: That is correct.
13 MR GARNHAM: Can you envisage circumstances in which it
14 would be reasonable for a social worker to have
15 a workload of 18?
16 MS BAPTISTE: If they were fairly experienced and confident
17 about carrying such a workload. In most cases I would
18 say that if they had a high workload, such as 18, it was
19 often because they were outstanding matters or cases
20 that needed to be closed that workers had not got round
21 to closing them.
22 MR GARNHAM: I see, so there would be rather fewer that were
23 active at the time?
24 MS BAPTISTE: That is correct.
25 MR GARNHAM: We have heard evidence that Lisa Arthurworrey

18
1 had a case load of about 18 or 19 cases at the time you
2 assigned her to Victoria's case. First of all, would
3 you agree that that is about right?
4 MS BAPTISTE: I believe so.
5 MR GARNHAM: In those circumstances was her workload
6 a reasonable one at the time you assigned her this
7 additional case?
8 MS BAPTISTE: I believe it was, given her experience.
9 MR GARNHAM: Did she report to you that she was overworked?
10 MS BAPTISTE: Stress or her stress management was something
11 that we did address and talk about.
12 MR GARNHAM: Was her overwork an element of her stress?
13 MS BAPTISTE: Yes, it was.
14 MR GARNHAM: What did you do about the fact that she was
15 saying she was stressed from overwork?
16 MS BAPTISTE: We tried to evaluate where the pressures were
17 coming from because the main bulk of her case load was
18 family support. The main stresses, as I understood it
19 at that time, seemed to be borne out of a lot of team
20 difficulties, disruptions, in terms of movement around
21 the team or the teams.
22 MR GARNHAM: Let me ask again, what did you do about the
23 fact that Lisa Arthurworrey was reporting to you that
24 she was stressed from overwork?
25 MS BAPTISTE: Well we looked at where those stresses were

19
1 coming from. You know, was it actually the case load or
2 was it a question of all these other dynamics going on
3 and --
4 MR GARNHAM: Having looked, what did you do?
5 MS BAPTISTE: I do not recollect clearly but I do remember
6 asking her if she was happy to go on with the 18 or
7 should I take some back.
8 MR GARNHAM: And what did she reply?
9 MS BAPTISTE: Well I think after we had gone through the
10 evaluation process of how she was coping and managing
11 the cases, it was agreed that she was okay with the
12 cases, that the stresses were coming or being borne out
13 of other things.
14 MR GARNHAM: I see. You tell us in your statement that
15 recruitment in Haringey was a long and arduous process.
16 Is that right?
17 MS BAPTISTE: It was not easy.
18 MR GARNHAM: What was it that caused the difficulty?
19 MS BAPTISTE: I suppose there are so many factors really.
20 North Tottenham I suppose was not regarded as a very
21 attractive office because first and foremost the
22 salaries or the financial incentives were not
23 particularly attractive, but I guess the primary problem
24 was really about trying to find experienced people from
25 the various agencies that were approached.

20
1 MR GARNHAM: So salary and finance is one problem. Were
2 there any other disincentives from joining the team at
3 North Tottenham District Office?
4 MS BAPTISTE: Not that I can think of. I think those were
5 the paramount reasons.
6 MR GARNHAM: During 1999 was your team up to establishment?
7 MS BAPTISTE: No.
8 MR GARNHAM: How many were you short?
9 MS BAPTISTE: I do not recall off the top of my head.
10 MR GARNHAM: Give us an impression. Was it one or two or
11 was it more?
12 MS BAPTISTE: Possibly two. I do not really recollect but
13 possibly two. At the time I am not sure.
14 MR GARNHAM: You tell us that one of the difficulties you
15 faced as a manager was the number of inexperienced
16 social workers in your team. Yes?
17 MS BAPTISTE: It was more to do with balance, that there was
18 not a balance.
19 MR GARNHAM: There was not enough experience?
20 MS BAPTISTE: Yes.
21 MR GARNHAM: Did you regard Lisa Arthurworrey as being one
22 of the experienced or one of the inexperienced social
23 workers?
24 MS BAPTISTE: I suppose given the context she was seen as
25 fairly experienced.

21
1 MR GARNHAM: She had been in the job about two years at the
2 start of the period with which we are concerned, early
3 1999, had she not?
4 MS BAPTISTE: That is correct.
5 MR GARNHAM: You regarded that, did you, as making her
6 a reasonably experienced social worker?
7 MS BAPTISTE: Yes.
8 MR GARNHAM: You tell us that the ergonomics and layout of
9 your office created problems in communication, is that
10 right?
11 MS BAPTISTE: Most definitely.
12 MR GARNHAM: And you have detailed that in your statement
13 and we can read that. What did you do to overcome that
14 problem?
15 MS BAPTISTE: My recollection of that time was that there
16 were a series of meetings about how to address those
17 problems.
18 MR GARNHAM: Yes, what happened?
19 MS BAPTISTE: I am trying to remember.
20 MR GARNHAM: Did anything change on the ground? Were the
21 ergonomics improved?
22 MS BAPTISTE: Not vastly but there were some attempts to
23 change some of the physical structure or structures of
24 the office layout because workers were very cramped and
25 there were health and safety issues, there were a lot of

22
1 wires on the ground and filing cabinets around or placed
2 in unsafe parts.
3 MR GARNHAM: That was improved, was it?
4 MS BAPTISTE: I suppose it could be looked at as an
5 improvement.
6 MR GARNHAM: You sound as if you were not entirely
7 satisfied.
8 MS BAPTISTE: No.
9 MR GARNHAM: What did you do? Did you report this to
10 anyone? Did you write to say that you had concerns?
11 MS BAPTISTE: No, I did not. Any concerns I had were
12 relayed verbally.
13 MR GARNHAM: To whom?
14 MS BAPTISTE: To either the Management Team --
15 MR GARNHAM: Who is that?
16 MS BAPTISTE: -- at the time or Dave Duncan.
17 MR GARNHAM: Who is the Management Team that you are
18 referring to? Carol Wilson?
19 MS BAPTISTE: Oh, my immediate peers.
20 MR GARNHAM: So that is Angella Mairs?
21 MS BAPTISTE: That is correct.
22 MR GARNHAM: Anybody else? If you cannot remember please
23 say so.
24 MS BAPTISTE: Okay, I cannot remember who was in the
25 Management Team at that time but certainly it was raised

23
1 in that forum and in raising it we would agree to meet
2 in a sub-group I suppose, but it was certainly raised in
3 the management meetings and borne out of those
4 discussions we would agree to meet separately.
5 MR GARNHAM: Was anything done about the residual concerns
6 you had about these layout problems?
7 MS BAPTISTE: Sorry, could you repeat?
8 MR GARNHAM: You told us that things improved initially but
9 that you had residual concerns about ergonomics and
10 layout and you have told us that as a result you
11 reported that to management and that there were groups
12 and sub-groups meeting. Was anything else done to put
13 matters right?
14 MS BAPTISTE: No, because it was felt that because of the
15 onset of restructuring and the uncertainty about how the
16 teams would be, I believe it was felt that it was better
17 to leave things as they were until the restructuring
18 process had occurred.
19 MR GARNHAM: I see, thank you. You also had management
20 difficulties in relation to a case of alleged
21 intimidation.
22 MS BAPTISTE: Yes.
23 MR GARNHAM: I do not want to ask you about the details of
24 that case because it is outside the matters with which
25 we are concerned, but I do want to know how that affair

24
1 affected the operation of the work in your team.
2 MS BAPTISTE: Okay.
3 MR GARNHAM: Can you tell us that please?
4 MS BAPTISTE: Yes. I would say that it had quite an immense
5 impact on the team.
6 MR GARNHAM: Affecting morale?
7 MS BAPTISTE: Yes, most definitely.
8 MR GARNHAM: Did it affect to your knowledge the quality of
9 the work your team were doing?
10 MS BAPTISTE: I suppose yes. Yes, yes, yes.
11 MR GARNHAM: Presumably it affected it adversely. The
12 quality of the work deteriorated because of this affair?
13 MS BAPTISTE: Yes.
14 MR GARNHAM: You are the manager of the team. What do you
15 do about not the details of the alleged intimidation but
16 managing its consequences?
17 MS BAPTISTE: Certainly it was something that I understood
18 to be managed between myself and my former manager.
19 MR GARNHAM: Mr Duncan?
20 MS BAPTISTE: That is correct.
21 MR GARNHAM: So how did you get over the fact that this
22 appeared to be affecting work?
23 MS BAPTISTE: We invited -- I say "we." There were a lot of
24 informal discussions where workers were invited to voice
25 their concerns or their unhappiness about the situation

25
1 and subsequently it led to a formal meeting with myself,
2 Dave Duncan and Angella Mairs.
3 MR GARNHAM: Do you remember when that meeting was?
4 MS BAPTISTE: I do not offhand, no.
5 MR GARNHAM: 1999 though?
6 MS BAPTISTE: Yes.
7 MR GARNHAM: Month, first half of the year, second half of
8 the year?
9 MS BAPTISTE: I do not recollect I am afraid.
10 MR GARNHAM: Before or after you first had sight of
11 Victoria's case?
12 MS BAPTISTE: I do not recollect.
13 MR GARNHAM: How long did this matter drag on for? How long
14 did it go on affecting the quality of work in your team?
15 Was it all dealt with in a week or --
16 MS BAPTISTE: No, it was not. It certainly was not dealt
17 with within a week.
18 MR GARNHAM: Give us an idea then. Two weeks, a month,
19 six months?
20 MS BAPTISTE: If I could have some time to think about that,
21 if I could write the question down and think about it
22 and come back to you on that.
23 MR GARNHAM: All right. So what I am wanting to know, and
24 it may well be that your counsel will make a note of it
25 so he can help you with it, is how long this affair

26
1 relating to the alleged intimidation affected the
2 quality of work in your team. I will come back and ask
3 you that again after we break.
4 MS BAPTISTE: Okay.
5 MR GARNHAM: You tell us that you spoke to Dave Duncan about
6 the problems you were having with managing this team.
7 That is right, is it not?
8 MS BAPTISTE: That is correct.
9 MR GARNHAM: What particular difficulties did you draw to
10 Mr Duncan's attention? Did you tell him about the
11 problem with ergonomics and layout of your office?
12 MS BAPTISTE: Yes, he was aware of those issues.
13 MR GARNHAM: Did you tell him about the difficulties you
14 were having with this alleged intimidation case?
15 MS BAPTISTE: He was aware of those issues too.
16 MR GARNHAM: Did you tell him about the overwork that you
17 have told us about?
18 MS BAPTISTE: He was aware of all those issues.
19 MR GARNHAM: And the difficulties you were having recruiting
20 to your team?
21 MS BAPTISTE: He was aware of all those issues.
22 MR GARNHAM: What advice did he give you about managing the
23 problems that resulted?
24 MS BAPTISTE: Again, I do not recollect specifically but
25 I think ultimately it resulted in us just ploughing on

27
1 as we always had done.
2 MR GARNHAM: So no change?
3 MS BAPTISTE: Certainly not any immediate change.
4 MR GARNHAM: In a sense, this is the stuff and substance of
5 management, is it not? Dealing with these sort of
6 problems is what managers are there for?
7 MS BAPTISTE: That is correct, but finding a solution is not
8 always an easy thing to do.
9 MR GARNHAM: I am sure that is right and if you cannot find
10 a solution you manage the problem, do you not?
11 MS BAPTISTE: You try to manage the problem.
12 MR GARNHAM: I am interested in knowing what you did to
13 manage these various problems. Is there anything else
14 you can tell us beyond what you have said so far?
15 MS BAPTISTE: I am not entirely clear what you want me to
16 say or answer to.
17 MR GARNHAM: It may be you cannot but if there is anything
18 else you can tell us about what you did in response to
19 these difficulties, then that would assist us. Nothing
20 else comes to mind?
21 MS BAPTISTE: Can I respond to that a bit later? I will
22 need to again think about that.
23 MR GARNHAM: I am sure Mr Herbert will have made a note of
24 that one as well, yes.
25 You mentioned several times restructuring and we

28
1 have heard a good deal of evidence about restructuring
2 in the course of this Inquiry. Can I ask you this about
3 that topic: when did you first hear about the plans for
4 restructuring in your department? Do you remember? Was
5 it at the beginning of 1999?
6 MS BAPTISTE: Possibly before that but I am not sure. There
7 was always some rumour around or passive information
8 around.
9 MR GARNHAM: Were you involved in any more active way in the
10 early discussions about how this process was going to be
11 conducted, and you are a manager of one of the teams
12 affected, were you involved in the discussions about how
13 the process should be introduced?
14 MS BAPTISTE: No, I was not involved.
15 MR GARNHAM: Did the department, Social Services Department
16 hold training sessions in relation to this
17 restructuring?
18 MS BAPTISTE: Not that I can recollect.
19 MR GARNHAM: I wonder whether you can have volume 29,
20 please, page 49. That is list of some of the training
21 courses that Haringey tell us you attended and we see at
22 the bottom, last item on that page, there is an activity
23 entitled "Redirecting the Work of the Department" and we
24 know from other evidence we have had that that is the
25 name given to the restructuring exercise.

29
1 MS BAPTISTE: Okay.
2 MR GARNHAM: That appears to record you as having signed up
3 for that course but then, last word on the page,
4 "withdrawing" from it. Do you remember withdrawing from
5 that course?
6 MS BAPTISTE: I cannot say that I do remember.
7 MR GARNHAM: Over the page please -- we ought to just note
8 that that one was dated 30th March. Over the page you
9 are enrolled for another training course with the same
10 title, this one for 28th May 1999, and it is indicated
11 that your attendance was approved, and then under the
12 date section there is an indication that you did not
13 show for that course. Do you recollect first of all
14 being enrolled for that course?
15 MS BAPTISTE: Yes, I do.
16 MR GARNHAM: And then not showing up?
17 MS BAPTISTE: Yes, I do.
18 MR GARNHAM: So the opportunity was there, was it, for you
19 to learn more about this restructuring exercise but you
20 were not able or did not choose to attend the course?
21 That appears to be right, does it not?
22 MS BAPTISTE: Yes. Sorry, yes.
23 MR GARNHAM: How long did this restructuring process take?
24 How long were your employers engaged on this exercise?
25 MS BAPTISTE: Sorry, can I go back to that point because

30
1 I am just trying to think about what is being said and
2 you asked me about whether there was any opportunity to
3 contribute, and the opportunities often arose in the
4 briefing sessions, from what I recollect.
5 MR GARNHAM: When were the briefing sessions?
6 MS BAPTISTE: I do not know. I cannot say offhand.
7 MR GARNHAM: Did you take up those opportunities? Did you
8 contribute in the briefing sessions?
9 MS BAPTISTE: There were a series of meetings and yes I did
10 contribute to some of those.
11 MR GARNHAM: And that was --
12 MS BAPTISTE: But the form -- with regards to formal
13 training, no, I did not attend any formal training on
14 that question.
15 MR GARNHAM: So you took part as a manager in the briefing
16 exercises that preceded this restructuring exercise but
17 you did not take part in the training exercises that
18 were laid on for staff in relation to that process; is
19 that right?
20 MS BAPTISTE: That is correct.
21 MR GARNHAM: How long did this restructuring process take in
22 your department?
23 MS BAPTISTE: I know it was quite a long time.
24 MR GARNHAM: Did you regard it as being drawn out or did you
25 think it was being done as fast as reasonably could be?

31
1 MS BAPTISTE: I think it was quite a long process.
2 MR GARNHAM: It was starting in early -- the first words you
3 heard about it I think you have told us was before the
4 beginning of 1999.
5 MS BAPTISTE: There was some hint, there was some hint.
6 MR GARNHAM: And I think it is right that you underwent your
7 interview in the course of this process in September, is
8 that right?
9 MS BAPTISTE: My interview for the restructuring process,
10 that is correct, yes.
11 MR GARNHAM: So it was certainly going on from the beginning
12 of 1999 through to September 1999 at least, was it not?
13 It seems to follow from what you have told us. Is that
14 right?
15 MS BAPTISTE: I am not quite sure what you are saying.
16 MR GARNHAM: I am just trying to get a picture of how long
17 staff at any level might have been affected by the
18 knowledge that there was a restructuring process in the
19 offing or taking place, and I am suggesting to you that
20 since you first heard about it at the end of 1998,
21 beginning of 1999, and you had your interview
22 in September 1999, it must have been running between
23 those two dates. Is that right?
24 MS BAPTISTE: I would say that certainly by summer there was
25 some clear documentation about restructuring.

32
1 MR GARNHAM: Yes, thank you, that is helpful, but it did not
2 finally get completed from what you have told us until
3 the autumn of 1999, if you were having your interview
4 in September. Does that sound about right?
5 MS BAPTISTE: It has been such a long time, I just cannot
6 remember everything, but in terms of the time sequence,
7 but it could be, I mean ...
8 MR GARNHAM: When you first realised that you were going to
9 need to apply to get your own job, to keep your own job
10 and you were going to be interviewed for that, did you
11 think about leaving Haringey?
12 MS BAPTISTE: Not initially.
13 MR GARNHAM: When did you contemplate leaving? When did you
14 first contemplate leaving?
15 MS BAPTISTE: Possibly around the September period before
16 the interviews.
17 MR GARNHAM: Could you have volume 29A back again please,
18 page 000.562. It is an undated memorandum from you to
19 Personnel asking this:
20 "I would appreciate an estimate quote regarding the
21 possible redundancy package that may be available
22 following restructuring."
23 So by the time you wrote that, you were certainly
24 thinking about the possibility of leaving Haringey, were
25 you?

33
1 MS BAPTISTE: Yes, it was given certainly in the briefing
2 that we or I received from Dave Duncan, and I say we
3 because we received the briefing as a management group,
4 but it was put to us that that was a possible outcome
5 from the restructuring.
6 MR GARNHAM: And you thought it would be worth finding out
7 what the financial package was going to be?
8 MS BAPTISTE: We were advised to. We were advised to at the
9 time.
10 MR GARNHAM: And you accepted that advice and wrote that
11 memo?
12 MS BAPTISTE: Yes.
13 MR GARNHAM: One needs to turn the page upside down but you
14 can see from the fax line on the bottom of the page that
15 that fax was sent on 4th August 1999, so would that be
16 about right, that you were making those enquiries in
17 early August?
18 MS BAPTISTE: Yes, yes.
19 MR GARNHAM: If you go on to the next page we see that the
20 following day Personnel wrote back to you giving you
21 a redundancy quote, 5th August 1999. Is that right?
22 MS BAPTISTE: Yes, that is correct.
23 MR GARNHAM: Once you got that redundancy quote did you go
24 on considering whether or not to take it and to leave
25 Haringey?

34
1 MS BAPTISTE: At that time I was not considering it as
2 a serious option. I think because of the briefing it
3 was suggested to us that we just look at it just in case
4 we wanted to consider it as an option but certainly when
5 I made those enquiries it was just out of interest more
6 than anything. I had not conclusively made a decision
7 or thought, "Right, I need to go", or that ...
8 MR GARNHAM: You were just looking at options?
9 MS BAPTISTE: That is correct.
10 MR GARNHAM: The reason I am interested is simply this, that
11 it happens that you were making those enquiries in
12 exactly the same week as you first came into contact
13 with Victoria's case and I am wondering whether it
14 affected the way you were doing your work.
15 MS BAPTISTE: I believe that Victoria's case was brought to
16 my attention on Duty by Angella Mairs round about the
17 30th, in fact it was brought to my attention on the
18 30th July.
19 MR GARNHAM: That is right and we know from evidence we have
20 already heard that Lisa Arthurworrey was visiting or
21 talking to Kouao and then visiting Victoria on 5th and
22 6th August, so the same sort of dates as you were
23 corresponding with Personnel about redundancy. My
24 question is simple, and the answer may simply be no, you
25 tell me. I am asking whether the fact that you were

35
1 contemplating as an option leaving Haringey was
2 affecting the way you were doing your work at that time?
3 MS BAPTISTE: No, that did not have an effect. The
4 restructuring process in terms of preparing for
5 interviews possibly had an impact.
6 MR GARNHAM: You were invited for interview I think on
7 9th September. If you go over to page 565 you will see
8 the invitation to the interview. Is that right?
9 MS BAPTISTE: That is correct.
10 MR GARNHAM: I think you told us that you had to prepare for
11 those interviews.
12 MS BAPTISTE: That is correct.
13 MR GARNHAM: Presumably your preparation started some time
14 after you received that letter of invitation, did it?
15 MS BAPTISTE: That is correct.
16 MR GARNHAM: And you then continued to prepare up until the
17 time of interview?
18 MS BAPTISTE: I certainly tried to. It was a very difficult
19 thing to do because what was apparent was that everyone
20 was in the same predicament of trying to find time to
21 prepare.
22 MR GARNHAM: This is not easy because you are applying for
23 your own jobs, are you not?
24 MS BAPTISTE: That is correct.
25 MR GARNHAM: Your interview took place on 22nd September?

36
1 MS BAPTISTE: Yes.
2 MR GARNHAM: During the period between those two dates,
3 a period of about 13 days, you have told us that you
4 were in contact with the Training Department, is that
5 right?
6 MS BAPTISTE: Yes, that is right.
7 MR GARNHAM: You made an effort to learn about the best
8 value process that the Government were introducing?
9 MS BAPTISTE: That is right.
10 MR GARNHAM: Were you doing this preparation during working
11 hours or were you doing it in your spare time?
12 MS BAPTISTE: Both.
13 MR GARNHAM: How much of your working time were you having
14 to devote to this preparation? An hour a day, six hours
15 a day or what?
16 MS BAPTISTE: I do not recollect. Probably about an hour
17 maybe. Maybe I would go off and do it in my lunchtime
18 or something like that.
19 MR GARNHAM: Were you doing anything during your ordinary
20 working hours, during the morning or the afternoon work?
21 MS BAPTISTE: Yes.
22 MR GARNHAM: Would there have been occasions when you would
23 have been engaged on that preparation rather than on
24 your ordinary job? It seems to follow from what you
25 have said.

37
1 MS BAPTISTE: Well, I am not quite clear what you are
2 saying, because ...
3 MR GARNHAM: You have told us that you had to go and talk to
4 the Training Department and you had to brush up on the
5 best value initiative.
6 MS BAPTISTE: Yes but that is in relation to the
7 restructuring process.
8 MR GARNHAM: Absolutely. I am simply trying to understand
9 whether some of that was done during working hours and
10 I think you have told us it was.
11 MS BAPTISTE: That is right, we had meetings and talks about
12 preparing for restructuring in working hours.
13 MR GARNHAM: Were you doing preparation for your interview
14 during working hours? There may be nothing wrong with
15 it, I do not know. I just want to know --
16 MS BAPTISTE: I am just trying to recollect if you give me
17 a moment. I think there was a time where we, all the
18 managers went across to the Training Department to
19 prepare a presentation.
20 MR GARNHAM: Yes. Were you doing anything else during
21 working hours in preparation for this interview?
22 I think you had to prepare a talk, a presentation.
23 MS BAPTISTE: That is what I am referring to.
24 MR GARNHAM: When you were preparing that presentation was
25 that during working hours?

38
1 MS BAPTISTE: Yes, that was.
2 MR GARNHAM: Will you give me the answer to the question
3 that I indicated I did not know earlier. Was this
4 permitted by your seniors, to prepare for this interview
5 during working hours?
6 MS BAPTISTE: There was not any formal time given, which is
7 I suppose if that were one of my criticisms that would
8 be one, because there was not any formal support as such
9 that had been identified for us to have that time.
10 MR GARNHAM: It might be said that you should have been
11 doing this preparation in your own time rather than
12 during Haringey's time. What would you say to that?
13 MS BAPTISTE: I think that in hindsight in terms of the
14 planning process that should have been an area that
15 should have been addressed because it did have an
16 impact.
17 MR GARNHAM: Because presumably it would have made you less
18 available to those for whom you were responsible.
19 MS BAPTISTE: That is correct.
20 MR GARNHAM: Part of the interview process you tell us
21 involves you undergoing certain tests.
22 MS BAPTISTE: That is correct.
23 MR GARNHAM: And you describe those as psychometric tests in
24 paragraph 27 of your statement.
25 MS BAPTISTE: That is correct.

39
1 MR GARNHAM: That is not right, is it? They were not
2 psychometric tests and you were told that?
3 MS BAPTISTE: That is right, we were told they were
4 psychometric tests.
5 MR GARNHAM: Have a look please at volume 29A which is the
6 one in front of you, page 000.568. Letter to you of
7 29th September from Carol Wilson, Assistant Director:
8 "I write in response to the points raised in your
9 letter of 28th September. You have concerns regarding
10 the tests used as part of the selection process. You
11 refer in your letter to psychometric testing. No
12 psychometric tests are used. That was a policy decision
13 undertaken by the Council."
14 So it is not right to say, is it, that you were
15 subjected to psychometric testing?
16 MS BAPTISTE: No, I think initially there was some confusion
17 about the concept of testing in this way because it had
18 been a new idea that had been introduced at this level.
19 MR GARNHAM: So why did you --
20 MS BAPTISTE: Fourth tier level. So people were -- I think
21 we were all unclear about the test and what it would
22 involve and entail.
23 MR GARNHAM: Why did you describe in your statement the
24 tests as being psychometric when they apparently were
25 not?

40
1 MS BAPTISTE: Because I did not remember that they were
2 referred to as occupational testing.
3 MR GARNHAM: Thank you.
4 MS BAPTISTE: When I wrote my statement I did not -- I had
5 not read lots of information to remind myself of certain
6 facts.
7 MR GARNHAM: When you wrote that they were psychometric you
8 had forgotten that you had been told expressly that they
9 were not?
10 MS BAPTISTE: I had not really thought about it. I just
11 wrote what I could.
12 MR GARNHAM: Thank you. You did not succeed in the
13 interview, did you?
14 MS BAPTISTE: That is correct.
15 MR GARNHAM: In fact you were deemed to be not appointable?
16 MS BAPTISTE: That is correct.
17 MR GARNHAM: As a result you were faced with a fairly stark
18 choice I think as to what you should do with your future
19 career, is that right?
20 MS BAPTISTE: What is a stark choice?
21 MR GARNHAM: I am using your words so perhaps we can look at
22 the letter, page 571 in this volume. 19th October,
23 letter from you to Carol Wilson:
24 "Dear Carol, I have received the news that I was
25 unsuccessful in my application for Team Manager's post.

41
1 I was also deemed not appointable. These outcomes have
2 presented me with a stark choice regarding my future
3 career."
4 That is where I got it from so you tell me what you
5 meant by "stark choice".
6 MS BAPTISTE: It is hard to say what I meant then but
7 I guess I felt that there were no other options for me
8 but to leave.
9 MR GARNHAM: So you were going to take up the redundancy
10 option which you pursued as a possibility earlier?
11 MS BAPTISTE: Yes.
12 MR GARNHAM: Prior to this interview did you see the writing
13 as being on the wall as far as your career with Haringey
14 was concerned? Did you recognise that those senior to
15 you were not amongst your warmest group of supporters?
16 MS BAPTISTE: That was not an issue for me really. I think
17 there were other factors going on in my life that made
18 it very difficult for me to feel settled in combination
19 with the whole experience of being in that team, the
20 Investigation and Assessment Team and what was going on.
21 MR GARNHAM: That brings me back to what I was asking
22 earlier. Were you thinking about the possibility of
23 leaving Haringey during August as a real possibility?
24 I am wondering whether you were getting these figures
25 for redundancy not just as a possibility that it was

42
1 worth bearing in mind but because you could foresee as
2 a real likelihood that you were not going to be kept on
3 by Haringey and therefore you were looking for the best
4 way out.
5 MS BAPTISTE: No, that is not an accurate picture at all.
6 I think that certainly there was a lot of uncertainty
7 for me. I also at that time had applied to do the
8 Management Diploma at the Open University which would
9 have entailed a commitment for at least several years to
10 Haringey, and I think that whatever you make of it,
11 there was a lot of commitment on my part to Haringey,
12 which is why I had been there for all those years, but
13 certainly at that time in my life there were factors
14 that were making it very difficult for me to feel
15 settled and so the question of leaving with or without,
16 although it was not uppermost in my mind, was lurking
17 around.
18 MR GARNHAM: I see. You tell us in paragraph 30 of your
19 statement that following a discussion with David Duncan
20 you understood that thereafter you would have no
21 managerial role in Haringey.
22 MS BAPTISTE: Sorry, could you say that again?
23 MR GARNHAM: Paragraph 30 of your statement:
24 "Following the feedback, I met with Dave Duncan to
25 discuss my future role. It was from this meeting that

43
1 I understood that technically I had no managerial
2 responsibility as my post had been deleted ..."
3 MS BAPTISTE: That is correct, yes.
4 MR GARNHAM: So you are saying, are you, that from the time
5 of the meeting with Dave Duncan you understood that you
6 were no longer a manager?
7 MS BAPTISTE: That is correct.
8 MR GARNHAM: When was the meeting with Duncan?
9 MS BAPTISTE: It was the following week. I do not know --
10 I could not say specifically but certainly I think it
11 was the Friday that the results came through. I may be
12 wrong but the results were phoned through on a Friday.
13 Do you have that information at hand?
14 MR GARNHAM: I do not have the information of the phone call
15 but we have looked at the letter that you wrote on
16 19th October indicating that you had been told that your
17 application had been unsuccessful, so would it have been
18 shortly after that that you understood you no longer had
19 a management role?
20 MS BAPTISTE: Yes, I guess so, yes.
21 MR GARNHAM: So middle or late October would be about the
22 period?
23 MS BAPTISTE: I guess so, yes.
24 MR GARNHAM: Again can you be helped with this, please,
25 page 000.582 in that volume. This is a handwritten

44
1 document prepared by Haringey. It is conceivable it is
2 wrong. Tell us if you think it is. This appears to
3 record you as ceasing to manage the DIA team on
4 5th November 1999. That is the fourth item down. Might
5 that be right? So not late October but the 5th November
6 when you cease having a management role?
7 MS BAPTISTE: I have to accept that. I have a recollection
8 that my role ceased earlier. I am not sure, other than
9 what I have referred to as having discussions with Dave,
10 where that came from.
11 MR GARNHAM: No.
12 MS BAPTISTE: But I have to accept that maybe there was
13 a misunderstanding.
14 MR GARNHAM: I want to make sure that I have understood both
15 sides of the misunderstanding. We have heard from
16 Lisa Arthurworrey, Day 26 page 22, that she understood
17 you ceased to be a manager at the end of 5th November.
18 We have also heard from Angella Mairs, who took over
19 your team I think, that she took over that team on
20 8th November, which was a Monday, and it sounds from
21 that evidence as if you stopped on the Friday
22 5th November and she picked up the reins on Monday the
23 8th. Might that be right?
24 MS BAPTISTE: It is very possible. I do not recollect that.
25 I have to be guided by you with that.

45
1 MR GARNHAM: Thereafter, according to your statement, back
2 to paragraph 30 of it, you agreed that you would, to use
3 your words, "help out". Yes?
4 MS BAPTISTE: That is correct.
5 MR GARNHAM: What do you mean by you agreed you would help
6 out?
7 MS BAPTISTE: I think we had, again my recollection was that
8 we had some loose discussions.
9 MR GARNHAM: Who is we?
10 MS BAPTISTE: Between myself and Dave Duncan. There were
11 some very loose discussions and I say loose because my
12 role was not defined as I recollect it but the paperwork
13 may be contrary to that, but my understanding of that
14 time was that he was not sure how I should be used
15 because there was no clear directive about what happened
16 to the fallout of staff who were unsuccessful with the
17 interview.
18 MR GARNHAM: When you wrote in your statement "I agreed to
19 help out", what did you mean?
20 MS BAPTISTE: Certainly I understood that helping out was
21 about giving advice to workers, that there was the --
22 there was the lack of clarity about my responsibilities
23 that made it difficult for me to understand what helping
24 out meant but it was open to interpretation I guess.
25 MR GARNHAM: We are at the moment looking at the period

46
1 after the date on which your managerial responsibilities
2 come to an end; we are looking at the period after that,
3 are we not? Before that you knew what your job was as
4 manager?
5 MS BAPTISTE: Yes.
6 MR GARNHAM: But after that you say your role was not
7 properly defined. Is that right?
8 MS BAPTISTE: Not initially. I mean I subsequently got
9 a defined role but there was a period where -- after the
10 interview where it was not very clear.
11 MR GARNHAM: I see. The time when you got a defined role is
12 mentioned in paragraph 57 of your statement when you say
13 that you became a project worker. You took on a project
14 role:
15 "... I was to act as a project worker and continue
16 to be managed by Dave Duncan."
17 MS BAPTISTE: That is correct, yes.
18 MR GARNHAM: So is the pattern that you continued in your
19 role as a manager up until the date, whenever it was,
20 when you were relieved of that job; thereafter for
21 a time your role was unclear and then later on you took
22 on the role as a project worker? Is that a fair
23 summary?
24 MS BAPTISTE: I would say so, yes.
25 MR GARNHAM: What were you doing as a project worker? What

47
1 projects were you working on?
2 MS BAPTISTE: Again, it was not clearly defined.
3 MR GARNHAM: Were they projects arising out of Quality
4 Protects?
5 MS BAPTISTE: Yes.
6 MR GARNHAM: Is it right that those projects did not involve
7 you in direct line management?
8 MS BAPTISTE: That is correct.
9 MR GARNHAM: I think you continued doing that until later
10 in November when you had some leave and then in December
11 you went sick and you did not return to Haringey again
12 before your employment was terminated in February, is
13 that right?
14 MS BAPTISTE: That is correct.
15 MR GARNHAM: After your job as Team Manager came to an end
16 I think it is right that you were offered the job of
17 Practice Manager?
18 MS BAPTISTE: That is correct.
19 MR GARNHAM: We find the offer of that at page 572 in this
20 same volume. Letter from Carol Wilson to you,
21 8th November:
22 "Sorry not to have written immediately ... awaiting
23 consideration of the Practice Manager gradings ... aware
24 that you have previously expressed an interest in
25 redundancy. I understand your wish to follow it up

48
1 again now ... unfortunately not within my gift.
2 Practice manager regrading means that you can be slotted
3 in on a one up one down arrangement."
4 So you were being considered then for a Practice
5 Manager's post?
6 MS BAPTISTE: That is correct.
7 MR GARNHAM: I think it is right that you did not
8 immediately respond to that letter and you were chased
9 up about it a little later, is that right?
10 MS BAPTISTE: Possibly, I do not recollect fully.
11 MR GARNHAM: But in the end you turned down that option, you
12 did not fancy the Practice Manager's post, is that
13 right?
14 MS BAPTISTE: No, it is not correct. I turned down the
15 option but it was not because I did not fancy the post.
16 MR GARNHAM: Tell us why it was.
17 MS BAPTISTE: I think I have referred to earlier when
18 I answered your question that there were a number of
19 factors that made it very difficult for me to be -- to
20 feel happy about continuing my work there.
21 MR GARNHAM: I see, so all of those factors together led you
22 not to pursue the Practice Manager's option, is that
23 right?
24 MS BAPTISTE: That is correct, yes.
25 MR GARNHAM: Your post was finally included in the Council's

49
1 redundancy programme on 20th December I think. We see
2 that from page 577 in that same volume. Is that right?
3 You are nodding.
4 MS BAPTISTE: Yes.
5 MR GARNHAM: But we know from what you have told us earlier
6 that by then you were away from the office because you
7 were taking leave and then unwell.
8 MS BAPTISTE: That is correct.
9 MR GARNHAM: And that in fact you do not come back to the
10 office before the post is terminated in February, is
11 that right?
12 MS BAPTISTE: That is correct.
13 MR GARNHAM: Thank you.
14 Sir I am about to move on to another topic.
15 I wonder whether this would be a convenient moment for
16 a short break.
17 THE CHAIRMAN: Thank you very much indeed. Ms Baptiste
18 normally it is not possible for witnesses to discuss
19 their evidence with anyone during these breaks but
20 I want to be as helpful as possible because your
21 evidence is very important to this Inquiry and very
22 important for you, so we will make an exception today
23 and someone will escort you to a private room where you
24 can meet with your legal team during the break and
25 I hope that that will help with your recollection when

50
1 you come back. Ladies and gentlemen we will adjourn
2 until a quarter to 12.
3 (11.35 am)
4 (A short break)
5 (11.45 am)
6 THE CHAIRMAN: Mr Garnham, can I make it plain that now if
7 people leave the building for any reason at any time for
8 however long, they have to hand in their security pass
9 downstairs, and when they return they have to go through
10 the same security arrangements that they went through
11 when they first came into the building. This is not the
12 security men at the bottom of the building being
13 difficult, this is my express instructions. Thank you
14 very much.
15 MR GARNHAM: Ms Baptiste, the reason Lord Laming permitted
16 you to speak to your counsel during the break was
17 because I asked you to reflect on two questions that we
18 had left hanging. First of all, how long did the
19 problems arising from the intimidation exercise affect
20 the work of your team? Can you help us with that?
21 MS BAPTISTE: Yes, I think it went on for possibly several
22 months.
23 MR GARNHAM: Thank you. Any idea when that period began?
24 MS BAPTISTE: I do not, off the top of my head no.
25 MR GARNHAM: Some time during 1999, you cannot be any more

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